Income Tax : Explore the rules and challenges of Domestic Transfer Pricing (DTP) in India. Learn about legal definitions, threshold limits, app...
Income Tax : Penalties for failing to maintain records of specified domestic transactions. Learn about arm's length pricing & essential documen...
Income Tax : Gain a comprehensive understanding of transfer pricing regulations with this informative article. Learn about Section 92A to 92F a...
Income Tax : The provisions of transfer pricing are designed to keep a check on the practice of reducing the tax liability by entering into tra...
Income Tax : The Finance Ministry vide Circular no. 17/2021 dated 09 September, 2021 announced extensions to the deadline for the filing of the...
Income Tax : From April 2025, TPOs can determine ALP for SDTs not initially referred or reported. This ensures accurate adjustments and complia...
Income Tax : The Income Tax Appellate Tribunal (ITAT) in Pune deleted the penalty in the Jyoti Paper Udyog Ltd Vs. ACIT case due to non-product...
Income Tax : ITAT Mumbai held that adjustment on account of examination of the arm’s-length price of the specified domestic transactions is n...
Income Tax : Finance Act, 2017 removed clause (i) of section 92BA, effectively nullifying any decisions made by the Assessing Officer under thi...
Income Tax : Held that a domestic transaction of purchase from the related party is not required to be considered as a specified domestic trans...
Income Tax : Garg Acrylics Ltd. Vs Addl. CIT (ITAT Delhi) It is the case of the assessee that reference made to the TPO in the instant case wit...
Income Tax : Notification No. 46/2023-Income-Tax Dated: 26th June, 2023 regarding deemed arm's length price for assessment year 2023-2024. Le...
Income Tax : Procedure for registration and submission of Statement of Reportable Account as per section 285BA of Income-tax Act, 1961 read wit...
Income Tax : Procedure for registration and submission of statement of financial transactions (SFT) as per section 285BA of Income-tax Act, 196...
Income Tax : As per sub-rule (1)(i) and sub-rule (4) of Rule 114D, the statement in Form No. 61 shall be furnished through online transmission ...
Income Tax : Under electronic verification, the individual or a person (not being a company or firm) who does not have a permanent account numb...
Under electronic verification, the individual or a person (not being a company or firm) who does not have a permanent account number and who enters into any transaction specified in under Rule 114B of the Income-tax Rules, 1962, shall make a declaration in Form No. 60 giving therein the particulars of such transaction electronically using electronic verification.
Budget 2017- it is proposed to provide that expenditure in respect of which payment has been made by the assessee to a person referred to in under section 40A(2)(b) are to be excluded from the scope of section 92BA of the Act. Accordingly, it is also proposed to make a consequential amendment in section 40(A)(2)(b) of the Act.
In this article we will explain about the provisions relating to penalty for failure to keep and maintain documents in respect of specified domestic transactions. However, before understanding the penalty provisions, one should have an overview of the basic provisions of transfer pricing in relation to specified domestic transactions.
In terms of the provisions, any income arising from an international transaction or specified domestic transaction between two or more associated enterprises shall be computed having regard to the Arm’s Length Price.
Introduction As we know the Finance Act 2012 has extended the scope of Transfer Pricing provisions to ‘Specified Domestic Transactions’ (SDT) between related parties w.e.f. AY 2013-14 by inserting section 92BA. Since its introduction there was ambiguity on its applicability to cooperative societies. There was no doubt of its applicability to cooperative societies claiming profit […]
Notification No. 90/2015 – Income Tax In the Income-tax Rules, 1962 (hereinafter referred to as the said rules), in rule 10D, for sub-rule (2A), the following sub-rule shall be substituted, namely:- (2A) Nothing contained in sub-rule (1), in so far as it relates to an eligible specified domestic transaction referred to in rule 10 THB , shall apply in a case of an eligible assessee mentioned in rule 10 THA and-
Transfer Pricing is the setting of the price for goods and services sold between controlled/related legal entities. It is generally aimed at depicting favourable performance of a conglomerate by shifting earnings from a high tax jurisdiction to a low-tax one.
The Finance Minister in his Budget speech, while introducing the Finance (No. 2) Bill 2014, had made an announcement that range concept for determination of ALP would be introduced in the Indian transfer pricing regime however, the arithmetic mean concept will continue to apply where the number of comparables is inadequate.
Raising the threshold for specified domestic transaction In a second blow to Chartered Accountants FM has raised Limit for Audit of Specified Domestic Transaction to Rs. 20 Crore from Rs. 5 Crore with effect from Assessment year 2016-17. This may effectively take 90% Assessees out of Ambit of Transfer Pricing Audit of Specified Domestic Transaction. […]
Notification No. 11/2015 – Income Tax 10THA. Eligible assessee.—The ‘eligible assessee’ means a person who has exercised a valid option for application of safe harbour rules in accordance with the provisions of rule 10THC, and is a Government company engaged in the business of generation, transmission or distribution of electricity.
